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MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge: In docket No. 7575-04, the Estate of Lillie
Rosen, Deceased, Ilene Field and Herbert Silver, Co-Personal
Representatives, petitioned the Court to redetermine respondent’s
determination of a $1,107,085 deficiency in the Federal estate
tax of the Estate of Lillie Rosen (decedent’s estate). In docket
No. 7576-04, the Estate of Lillie Rosen, Deceased, Donor, Ilene
Field and Herbert Silver, Co-Personal Representatives, petitioned
the Court to redetermine respondent’s determination of a $25,826
deficiency in the 2000 Federal gift tax of Lillie Rosen
(decedent). The cases resulting from these petitions were
consolidated for purposes of trial, briefing, and opinion.
Following concessions by the parties and a trial of the
remaining issues, we decide whether decedent retained the
possession or enjoyment of, or the right to the income from,
property transferred to the Lillie Rosen Family Limited
Partnership (LRFLP) with the result that the property is
includable in her gross estate under section 2036(a)(1).1 We
hold she did. Given this holding, we need not and do not
consider respondent’s other arguments in support of respondent’s
1 Unless otherwise indicated, section references are to the
applicable versions of the Internal Revenue Code. Rule
references are to the Tax Court Rules of Practice and Procedure.
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